Party Discovery: Myrtle Doctor, et al Plaintiff vs. Universal Property And Casualty Insurance Company Defendant

On December 31, 2021 a Party Discovery was filed involving a dispute between Doctor, Hopeton, Doctor, Myrtle, and Universal Property And Casualty Insurance Company, for 3 in the District Court of Broward County.

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Filing# 181025150 E-Filed 09/01/2023 04:03:41 PM

IN THE CIRCUIT COURT IN AND FOR
BROWARD COUNTY, FLORIDA
MYRTLE & HOPETON DOCTOR, CASE NO.: CACE-22-000063

Plaintiffs,
VS.

UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,

Defendant.
i

DEFENDANT'S NOTICE OF TAKING DEPOSITION DUCES TECUM USING
COMMUNICATION TECHNOLOGY
PLEASE TAKE NOTICE that Defendant, UNIVERSAL PROPERTY & CASUALTY

INSURANCE COMPANY, will take the depositionset forth below:

NAME DATE TIME
Laila Rubi October 4,2023 10:00 a.m.

LOCATION: EsquireDeposition Solutions via Zoom 1

TO JOIN ZOOM MEETING:
ENTER MEETING ID: 97694773135
ENTER PASSCODE: 10234716

Upon oral of Esquire Deposition Solutions, or any
examination before a representative

other officer authorized by law to take depositionsin the State of Florida. The oral examination

will continue from day to day until completed.

This depositionis being taken for the purpose of discovery,for use at or both of the
trial,

foregoing,or for such other purposes as are permittedunder the Florida Rules of Civil Procedure

1This depositionwill occur remotely in accordance with Fla. R. Civ. P. 1.310(b)(7)by stipulation
ofthe parties.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/01/2023 04:03:40 PM.****
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 2 of 5

and other applicablelaw. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the

deponent have the followingitems listed in Schedule "A" at the time and place of the foregoing

for purposes of inspectionand/or copying by
deposition, this Defendant.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 1st day of September 2023, a true and correct copy of

the foregoingwas filed with the Clerk of Court by using the Florida Courts e-FilingPortal,which

will send an automatic e-mail message to: Slava Borshchukov, Esquire of VYACHESLAV

BORSHCHUKOV, P.A.; service@vb.legal.

AttorneyMDefendant
Universal Property & Casualty Insurance Company
P.O. Box 9388
Fort Lauderdale, Florida 33310

Legal Assistant Telephone: 954-320-7546
ReceptionistTelephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: (954) 958-1262

By.- /s/ Karen E. Berger
Karen E. Berger,Esq.
Florida Bar No. 72991

For Service of Court Documents onlv:
Primary:
upciceservice09@universalproperty.com
Secondary: am0419@universalproperty.com
Tertiary:
kb0530@universalproperty.com

For Scheduling Matters:
am0419@universalproperty.com

:Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com
or upciceservice09@universalproperty.com.
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 3 of 5

ATTACHMENT"A"
1. Your entire file(s), to the property located at 3 910
cover-to-cover, relating NW 3 1 ST TER.,
LAUDERDALE LAKES, FL 33309, includingbut not limited to:

a. Any and all contracts, agreements, amendments, addendums with the
insureds;

b. Any and correspondence,e-mail correspondence,and facsimile
all to the
insureds or the insured's agent from you;

c. Any and all correspondencefrom the insureds or the insured's agent to you;

d. Any and all correspondence,e-mail correspondence,and facsimile sent by
you or received by you from any third party;

e. Any and all documents relatingto the evaluation of the property;

f. Any and all inspections,
estimates, or reports of the property;

g. Any and all inspections,estimates, or reports provided to you by third
parties;

h. Any and all reports, logs, notes, calendar entries,or other
memoranda,
documents regardingthe insureds or the insured's agent or the property;

i. Any and all measurements, samples, worksheets, and diagrams ofthe property;

j. Any and all internal
working papers, correspondence, notes, preliminary
reports, report work-sheets, graphs,surveys, studies,safetystandards, or other
documentation or data prepared by you or anyone associated with you or
employed by you. Any document containinginformation related directlyor
indirectly to any proposed expert advice, opinionsor testimonywhich you have
or may render regarding the property located at 3910 NW
31ST TER.,
LAUDERDALE LAKES, FL 33309.
k. Any and photographs and/or videographs. Please provide color
all

photographs. If there is cost involved with producing color photographs,
please contact the undersigned with a cost-estimate.

1. Any and all measurements, samples,worksheets, and diagrams;

m. Any and evidence ofany request for payment ofpayment(s)by the insureds,
all

includinginvoices,checks, bills,and statements for your services in this matter.

2. Copies of any and all reports, drafts,charts,drawings,diagrams, and memoranda and/or
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 4 of 5

resultsof any testingshowing or intending to show the cause of damage to insured's
property located at 3910 NW
31ST TER., LAUDERDALE LAKES, FL 33309.

3. All telephonemessages to or from you, or any of your employees or contractors regarding

requests for service and/or repairof the subjectproperty located at 3910 NW
31ST TER.,
LAUDERDALE LAKES, FL 33309.

4. Any removed from the insured's
material or property that you or your representatives
residence or business located at 3910 NW
31ST TER., LAUDERDALE
LAKES, FL
33309.

5. All documents reflecting any payment made to you by any person or entityfor any reason
as a result of insured's claim for damages allegedlyoccurringon December 7,2020, at
3910 NW 31ST TER., LAUDERDALE LAKES, FL 33309.
6. All tapes and or transcripts
of statements taken of any person regardingthe insured's claim
for damages occurring on December 7,2020, for the property located at 3910 31ST NW
TER., LAUDERDALE LAKES, FL 33309.

7. All writings, examination o f the property
memoranda, notes or other materials reflecting
located at 3910 NW 31ST TER., LAUDERDALE LAKES, FL 33309, by Deponent orits
agents with respect to the allegeddamage occurringon December 7,2020.

8. A copy of any and all documents maintained by Deponent pertainingto its pricingpolicies
and proceduresin place for the Broward County on December 7,2020.

9. Copies of any and all manuals, service manuals or instruction manuals for the equipment
utilized at the property located at 3910 NW 31ST TER., LAUDERDALE LAKES, FL
33309.

10. The name and current address of any individual that performed work at the insured's
residence.

11. A complete copy of the personnel file for any individual that performed work at the
insured's residence.

12. Complete copiesof the time-sheets,punch-cardsor other evidence of time spent working
for any and all employees or individuals that performed work at the insured's residence for
all days that Deponent performed work at insured's home located at 3910 NW
31 ST TER.,
LAUDERDALE LAKES, FL 33309.

13. A complete copy of any and all documents, records, sheets, forms, etc. evidencing the
equipment utilized at the property located at 3910 NW
31 ST TER., LAUDERDALE
LAKES, FL 33309.

14. Copies of any and all photographs or videotape taken of the area(s)of the interior of the
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 5 of 5

home located at 3910 NW 31ST TER., LAUDERDALE LAKES, FL 33309, with respect
to the allegeddamage occurringon December 7,2020.

15. Copies of any and all correspondencebetween insured's and any contractor, repair/service
company providing any services or preparing any estimate for repairswith respect to
allegeddamage occurring on December 7,2020.

16. Copies of any documents which support any claim with respect to the allegeddamage
occurringon December 7,2020.

17. Copies of any and all invoices,cancelled checks or other evidence of payment for repairs,
remodels or renovations made to 3910 NW31ST TER., LAUDERDALE LAKES, FL
33309, for the five (5)years priorto the date of loss.

18. Copies of any and all inspections, or other investigations
appraisals for the property located
at 3910 NW 3 1 ST TER., LAUDERDALE LAKES, FL 33309, priortothe date ofpurchase.

19. The Curriculum Vitae (CV) for Deponent.

20. All professional
licenses for Deponent.

21. All occupationallicenses for Deponent.
IN THE CIRCUIT COURT IN AND FOR
BROWARD COUNTY, FLORIDA
MYRTLE & HOPETON DOCTOR, CASE NO.: CACE-22-000063

Plaintiffs,
VS.

UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,

Defendant.
i

SUBPOENA DUCES TECUM FOR DEPOSITION

TO: Laila Rubi

Century Public Adjusters
1021 Ives Dairy Rd., Suite #111
Miami, FL 33179

YOU ARE COMMANDED to appear before a person authorized by law to take

depositionson October 4, 2023, at 10:00 AM via Zoom, Esquire Deposition Solutions,

https://esquiresolutions.zoom.us/i/97694773135?pwd=TUJKYXhTWGVTbEdYU2phtlB5

ViJWUT09, for the takingof your depositionin this action and to have with you at that time and

placethe following:

ALL MATERIALS LISTED IN 'ATTACHMENT A". ,,

Attached hereto and incorporatedherein by reference.

IF YOU FAIL TO APPEAR, you may be in contempt of court. You are subpoenaed to

appear by the following attorney, and unless excused from this subpoena by this attorney or the

court, you shall respond to this subpoena as directed.

ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF
IN
1990 (ADA), ALL PERSONS WHO ARE DISABLED AND NEED SPECIAL
ACCOMMODATIONS TO PARTICIPATE IN THIS PROCEEDING BECAUSE OF
THAT DISABILITY SHOULD CONTACT KAREN BERGER, ESQUIRE, AT
TELEPHONE (954) 958-1200 WITHIN 2 WORKING DAYS OF YOUR RECEIPT OF
THIS SUBPOENA; IF YOU ARE HEARING OR VOICE IMPAIRED, CALL 711.
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 2 of 5

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 1st day of September 2023, a true and correct copy of

the foregoingwas filed with the Clerk of Court by using the Florida Courts e-FilingPortal,which

will send an automatic e-mail message to: Slava Borshchukov, Esquire of VYACHESLAV

BORSHCHUKOV, P.A.; service@vb.legal.

AttorneyMDefendant
Universal Property & Casualty Insurance Company
P.O. Box 9388
Fort Lauderdale, Florida 33310

Legal Assistant Telephone: 954-320-7546
ReceptionistTelephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: (954) 958-1262

By.- /s/ Karen E. Berger
Karen Berger,Esq.
Florida Bar No. 72991

For Service of Court Documents onlv:
Primary:
upciceservice02@universalproperty.com
Secondary: am0419@universalproperty.com
Tertiary:
kb0530@universalproperty.com

For Scheduling Matters:
am0419@universalproperty.com

:Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com
or upciceservice02@universalproperty.com.

In accordance with the Americans with Disabilities Act of 1990, persons needing a special accommodation to participate
in this proceeding should contact Attorney ADA Coordinator no later than seven days prior to the proceeding. Telephone
(305)461-2445.for assistance; if hearing impaired, telephone Florida Relay Service at (800) 955-8771.for assistance.
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 3 of 5

ATTACHMENT"A"
1. Your entire file(s), to the property located at 3 910
cover-to-cover, relating NW 3 1 ST TER.,
LAUDERDALE LAKES, FL 33309, includingbut not limited to:

a. Any and all contracts, agreements, amendments, addendums with the
insureds;

b. Any and all correspondence,e-mail correspondence,and facsimile to the
insureds or the insured's agent from you;

c. Any and all correspondencefrom the insureds or the insured's agent to you;

d. Any and correspondence,e-mail correspondence,and facsimile sent by
all

you or received by you from any third party;

e. Any and all documents relating
to the evaluation of the property;

f. Any and all inspections,estimates, or reports of the property;

g. Any and all estimates,or reports provided to you by
inspections, third

parties;

h. Any and all memoranda, reports, logs, notes, calendar entries,or other

documents regardingthe insureds or the insured's agent or the property;

i. Any and all measurements, samples, worksheets, and diagrams ofthe property;

j. Any and all internal
working papers, correspondence,notes, preliminary
reports, report work-sheets, graphs,surveys, studies,safetystandards, or other
documentation or data prepared by you or anyone associated with you or
employed by you. Any document containing information related directlyor
to any proposed expert advice,opinionsor testimonywhich you have
indirectly
or may render regarding the property located at 3910 31ST TER.,NW
LAUDERDALE LAKES, FL 33309.
k. Any and all photographs videographs. Please provide color
and/or

photographs. If there is cost involved with producing color photographs,
please contact the undersigned with a cost-estimate.

1. Any and all measurements, samples, worksheets, and diagrams;

m. Any and all evidence ofany request for payment ofpayment(s)by the insureds,
includinginvoices,checks,bills,and statements for your services in this matter.

2. Copies of any and all reports, drafts,charts,drawings,diagrams, and memoranda and/or
results of any testingshowing or intendingto show the cause of damage to insured's
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 4 of 5

property located at 3910 NW 31ST TER., LAUDERDALE LAKES, FL 33309.
3. All telephonemessages to or from you, or any of your employees or contractors regarding
requests for service and/or repairof the subjectproperty located at 3910 NW
31ST TER.,
LAUDERDALE LAKES, FL 33309.

4. Any removed from the insured's
material or property that you or your representatives
residence or business located at 3910 NW
31ST TER., LAUDERDALE
LAKES, FL
33309.

5. All documents reflecting any payment made to you by any person or entityfor any reason
as a result of insured's claim for damages allegedlyoccurring on December 7,2020, at
3910 NW 31ST TER., LAUDERDALE LAKES, FL 33309.
6. All tapes and or transcripts
of statements taken of any person regardingthe insured's claim
for damages occurringon December 7,2020, for the property located at 3910 31ST NW
TER., LAUDERDALE LAKES, FL 33309.

8. A copy of any and all documents maintained by Deponent pertainingto its pricingpolicies
and proceduresin place for the Broward County on December 7,2020.

9. Copies of any and all manuals, service manuals or instruction manuals for the equipment
utilized at the property located at 3910 NW 31ST TER., LAUDERDALE LAKES, FL
33309.

10. The name and current address of any individual that performed work at the insured's
residence.

11. A complete copy of the personnel file for any individual that performed work at the

insured's residence.

12. Complete copies of the time-sheets,punch-cards or other evidence of time spent working
for any and all employees or individuals that performed work at the insured's residence for
all days that Deponent performed work at insured's home located at 3910 NW
31 ST TER.,
LAUDERDALE LAKES, FL 33309.

13. A complete copy of any and all documents, records, sheets,forms, etc. evidencing the
equipment utilized at the property located at 3910 NW
31 ST TER., LAUDERDALE
LAKES, FL 33309.

14. Copies of any and all photographs or videotape taken of the area(s)of the interior of the
home located at 3910 NW 31ST TER., LAUDERDALE LAKES, FL 33309, with respect
Myrtle & Hopeton Doctor VS. Universal Property & Casualty Insurance Company
CASE NO.: CACE-22-000063
Page 5 of 5

to the allegeddamage occurringon December 7,2020.

15. Copies of any and all correspondencebetween insured's and any contractor, repair/service
company providing any services or preparingany estimate for repairswith respect to
allegeddamage occurringon December 7,2020.

16. Copies of any documents which support any claim with respect to the alleged damage
occurringon December 7,2020.

17. Copies of any and all invoices,cancelled checks or other evidence of payment for repairs,
remodels or renovations made to 3910 NW
31ST TER., LAUDERDALE LAKES, FL
33309, for the five (5)years priorto the date of loss.

18. Copies of any and all inspections, or other investigations
appraisals for the property located
at 3910NW 3 1 ST TER., LAUDERDALE LAKES, FL 33309, priortothe date ofpurchase.

19. The Curriculum Vitae (CV) for Deponent.

20. All professional
licenses for Deponent.

21. All occupationallicenses for Deponent.

Case Info

Judge

Robinson, Michael A. Track Judge’s New Case

Case No.

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Document Filed Date

September 01, 2023

Case Filing Date

December 31, 2021

County

Parties

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